S.37(1): Business expenditure-Statutory reserve fund-Amounts transferred to statutory reserve fund in compliance with mandatory provisions of Reserve Bank of India Act, 1934-No diversion of income-Not allowable as deduction.[S. 4, Reserve Bank of India Act, 1934 S. 45-IC, 45Q.]

S. 36(1)(va): Any sum received from employees-Not paid before due date-Disallowance was affirmed. [S.260A]

S. 36(1)(iv) : Contribution towards a recognized provident fund-Business expenditure-Payments made on next day since due date fell on National holiday-Deductible.[37(1), 260A]

S. 17(2) : Salary-Perquisite-Stock options provided to ex employees-Stock options were not a perquisite; no exercise of options-No income chargeable to tax-Not liable to deduct tax at source. [S. 5, 17(2)(vi), 197, Art. 226]

S. 17(2): Salary-Perquisite-Valuation of shares-Face value-Shares allotted as part of employee stock purchase scheme Lock-in period during which shares could not be transferred-Valuation of shares taking into account restrictive condition. [ S. 17(2)(iiia), 260A]

S. 12A: Registration-Trust or institution-Cancellation of registration-Treating donation as corpus and later treating as general donation and paying tax as per order of Settlement Commission under section 245C-Cancellation of registration not valid.[ S. 12AA(3), 245C, 260A ]

S. 4 : Charge of income-tax-Capital or revenue receipt-Security deposits-High Court admitted appeal to decide whether Tribunal was justified in treating amount received as security deposit which was forfeited as a capital receipt. [S. 260A]

S.80IA: Industrial undertakings – Enterprises engaged in infrastructure development -Income tax refund – Interest on excess payment of tax – Income derived from eligible business – Eligible for deduction- No substantial question of law . [ S.260A ]

S.80IA: Industrial undertakings – Enterprises engaged in infrastructure development -Derived – Interest income on fixed deposits kept for contractual obligations and Interest on wrongful deduction of TDS refund – Eligible for deduction as profits derived from infrastructure facility. [ S. 56 ,80IA(ii), 254(2), 260A , Art.226 ]

S. 69C : Unexplained expenditure – Bogus purchases -Information from sales tax department – Bogus accommodation entries – Purchases – Payments through banking channels – Sales accepted – Addition restricted to 5 percent – PCIT v. Kanak Impex (India) Ltd. [2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC) distinguished. [ S. 143(3) ]